On April 30, 2019, the U.S. Department of Justice
("DOJ") issued the most comprehensive guidance that the
DOJ has provided on how prosecutors should evaluate corporate
compliance programs ("Policy"). In a speech announcing the Policy, Assistant
Attorney General for the Criminal Division, Brian A. Benczkowski
expressed the DOJ's desire "to provide additional
transparency" to companies in designing and implementing
compliance programs.
The Policy was published by the DOJ's Criminal Division,
which is responsible for cases involving the Foreign Corrupt
Practices Act, securities and financial fraud, asset forfeiture,
and anti-money laundering. It is expected that this Policy will be
implemented by the DOJ Criminal Division and U.S. Attorney's
Offices.